Fairfax- Falls Church Community Services Board agrees and supports the comments/feedback below:

1. Chapter 4, Covered Services and Limitations-Page 36:

Criteria/Allowable Activities

A person who receives support coordination services must have a person-centered Individual Support Plan (ISP) in effect which requires at least a monthly direct or individual-related contact, communication or activity with the individual, family / caregiver, service provider(s), or significant others, including at least one face-to-face contact with the individual every 90 days. A 10 day grace period is permitted for the face-to-face contact; however, if the grace period is used, it does not change the original 90 day due date.

• Comments/feedback: Fairfax-Falls Church Community Services Board supports the proposed change to allowing a 10 day grace period for a 90 face-to-face contact.

2.  Chapter 6, Quality Management and Utilization Reviews-Page 18

Required Documentation            

Documentation will be maintained in accordance with applicable statutes and policies. Waiver services that fail to meet DMAS criteria are not reimbursable. Reimbursement is not permitted in the following situations (not an all-inclusive list): · Service authorization not obtained and/or not available at DMAS’ request; · Request for service authorization not submitted by the provider; · Patient pay requirement for the individual, but not indicated on CMS-1500 and paid by DMAS; · The provider does not meet the qualification criteria; · The provider staff’s personnel files fail to verify that the minimum qualifications outlined in Chapter II are met; · The individual resides in a nursing facility (NF), an ICF/IID, or a hospital; or · Duplicate hours or units are billed.

• Comments/feedback: Further guidance is needed around the billing process for targeted case management when an individual’s services have been interrupted due to a hospitalization/and or nursing home admission. 

3. Chapter 4, Covered Services and Limitations- Page 31

Discharging an Individual from DD Waiver Services

DMAS and DBHDS will ensure only eligible individuals receive DD waiver services and will remove the individual from the waiver and close all services when the individual is no longer eligible for the waiver. Discharge from the DD Waivers must occur when: · The individual's health, safety, and welfare and medical needs can no longer be safely met in the community, · The individual is no longer eligible for either Medicaid or no longer meets the ICF/IID level of care or diagnostic eligibility, · The individual was eligible for one of the waivers and accepted a waiver slot but did not start services for five months, · The individual moves to another state, · The individual declines DD waiver services, · The individual enters an ICF/IID, NF, or rehabilitation hospital, · The local department of social services determines that the individual is no longer financially eligible, · HCBS are not the critical alternative to prevent or delay ICF/IID placement, · An appropriate and cost-effective ISP cannot be developed, · The individual is deceased.

• Comments/feedback: Clarity is needed regarding on the timeframe when an individual should be discharged from DD waiver services, due to not finding a provider who can support their behavioral/ and or medical needs.